The Jade ThirdEye team recently hosted an exclusive roundtable lunch at the Shangri-La Hotel, in partnership with Refinitiv, where we were joined by AML specialists across a number of sectors as we discussed ‘Modernising your approach to Financial Crime’ and the key aspects of automation.
The roundtable was facilitated by Colin Dixon (Jade ThirdEye Product and Account Manager), alongside panellists Laura Manning (Customer and Digital Identity Solution Sales, Refinitiv), Aub Chapman (Director, Aub Chapman Consulting Services Pty Ltd / Co-Chair, ACAMS Australasian Chapter) and Jeremy Moller (Senior Advisor - Risk Advisory, Norton Rose Fulbright Australia).
For those who couldn’t join us on the day, here’s what you missed:
The purpose of transaction monitoring is to identify activity that presents a risk of money laundering or other financial crime. The risks are specific to each individual business, so a successful transaction monitoring program should always start with a risk assessment.
Risks are not constant, but will evolve due to internal and external factors. A transaction monitoring program is not a “set and forget” exercise, it needs to evolve in line with the risks. It’s all too common to be using rules that were set up years ago and are continually giving too many false positives for an overworked team to keep on top of. You should have a process in place to identify changes needed and then to make and test the changes before you make them live.
Customer screening to identify PEPs and sanctioned people and entities has always been a key part of an AML program, but has a raised awareness following the Russian invasion of Ukraine. Sanction lists are updated regularly and it is important to ensure customers are checked against the updated lists daily.
Your approach to screening should also refer back to your risks and should be a balance between ensuring every customer is screened thoroughly and surfacing too many unnecessary false positives.
Assurance is becoming a subject with a higher profile as senior managers want more visibility that their AML team are following correct processes. From an automation point of view this really means “how do you know the system is doing what it claims to do?”. Don’t assume that it is working correctly. Put reports and checks in place to satisfy yourself, your managers and your auditors.
The basic principles of successful automation are simple:
- Identify your risks
- Put automation in place to address those risks
- Keep making adjustments to match your changing risks
- Trust but verify that the automation is working as intended
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